Title IV Code of Conduct Requirements

A ban on revenue-sharing arrangements with any lender. This is defined as any arrangement between a school and a lender that results in the lender paying a fee or other benefits, including a share of the profits, to the school, its officer, employees or agents, as a result of the school recommending the lender to its students or families of those students.
A ban on employees of the the Office of Financial Aid from receiving gifts from any lender, guaranty agency, or loan servicer. This is not limited just to those providers of the Title IV loans. The statutory language refers to lenders of "educational loans" thus private education loans offered to students at your institution are covered in this provision as well. The law does provide for some exceptions related to specific types of activities or literature. This includes:
- Brochures or training material related to default aversion or financial literacy;
- Food, training, or informational materials as part of training as long as that training contributes to the professional development of those individuals attending the training;
- Favorable terms and benefits to students employed by the institution unless those same terms are provided to all students at the University;
- Entrance and exit counseling as long as University staff are in control and do not promote the services of a specific lender;
- Philanthropic contributions from a lender, Graduate Agency or servicer unrelated to education loans;
- State education, grants, scholarships, or financial aid funds administered by or on behalf of the State;
A ban on contracting arrangements whereby any employee of the school's financial aid office accepts any fee, payment or financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
A prohibition against steering borrowers to particular lenders, or delaying loan certifications. This includes assigning any first-time borrower's loan to a particular lender as part of their award packaging or other methods.
A prohibition on offers of funds for private loans. Schools may not request or accept such offers. This includes any offer of funds for loans to students at the University, including funds for an opportunity pool loan, in exchange for providing concessions or promises to the lender for a specific number of loans, or inclusion on a preferred lender list.
A ban on staffing assistance from a lender. Schools may not request or accept any assistance with call center staffing or Office of Financial Aid. However, the law does not prohibit schools from requesting or accepting assistance from a lender related to:
- Professional development training for financial aid administrators.
- Providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials do not disclose to borrowers the identification of any lender that assisted in preparing or providing such materials.
- Staffing services on a short-term, nonrecurring basis to assist the school with financial aid-related functions during emergencies, including State-declared or federally declared natural disasters, and other localized disasters and emergencies.
A ban on advisory board compensation. Employees of the University may not receive anything of value from a lender, guarantor, or group in exchange for serving in this capacity. They may, however, accept reimbursement for reasonable expenses incurred while serving in this capacity.